Place of Provision of Goods Transport Service. The place of provision of services of goods transport service, other than by way of mail or courier, shall be the place of destination of the goods. However, the place of provision of services of goods transportation service agency shall be the location of the person liable to pay tax [Rule 10 of Place of Provision of Service Rules].
This specific provision has been made as in the case of GTA service, a person paying freight is liable to pay service tax. In case of courier or mail services, if both service provider and service receiver are in a taxable territory (India), taxable territory (India) will be a place of provision of service as per rule 8 of Place of Provision of Service Rules and service tax will be payable even if goods are carried outside India.